March 23, 2018 

DISCLAIMER; This is a working document provided by the Centers for Disease Control and Prevention (CDC) technical support contractor, SC&A, for use in 

discussions with the National Institute for Occupational Safety and Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its 

Working Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, draft or working documents are not final NIOSH or ABRWH 

products or positions, unless specifically marked as such. This document prepared by SC&A represents its preliminary evaluation on technical issues. 

NOTICE: This document has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

ISSUES RESOLUTION MATRIX FOR ORAUT-OTIB-0017, REVISION 01,

“INTERPRETATION OF DOSIMETRY DATA FOR ASSIGNMENT OF SHALLOW DOSE”

Finding 

Number Finding Description NIOSH Response Finding Resolution

1 The OTIB needs to provide additional 

guidance regarding how to interpret film 

badge data with respect to beta vs.

low-energy photon exposure for the purpose 

of reconstructing shallow doses.

It is suggested that the dose reconstructor 

check whether the site was reporting dose due 

to electrons or photons, and whether the 

dosimetry system had been calibrated for that 

type of radiation.

9/25/2007: DR staff has access to that type of 

information in the site profile documents and 

other supporting documentation such as TIBs. 

For example, an SRS claim would make use of 

Attachment B to ORAUT-OTIB-0017 

(Attachment B, “Skin Dose Assignment for 

Savannah River Site Cases”), OCAS-TIB-0006 

(Section 3, “Shallow Dose Interpretation”), and 

the site profile document. In addition, there is 

evidence of over-response of film dosimeters to 

low-energy photons (as discussed on page 9 of 

ORAUT-OTIB-0017).

10/2/2007: The Subcommittee for Procedure 

Reviews (SCPR) found NIOSH’s response 

acceptable and closed this finding.

2 The OTIB assumes that the protective 

clothing used for each case was known in 

the majority of cases and the appropriate 

clothing-specific transmission factors can be 

selected.

10/2/2007: NIOSH explained that there is 

language in the OTIB that allows the dose 

reconstructor to choose the appropriate clothing 

shielding factors based on whether a minimizing, 

maximizing, or a realistic analysis of beta dose is 

being performed. SC&A concurs with this 

response.

10/2/2007: The SCPR found NIOSH’s 

response acceptable and closed this finding.
Issues Resolution Matrix for OTIB-0017 2 SC&A – March 23, 2018

NOTICE: This document has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 

Number Finding Description NIOSH Response Finding Resolution

3 It is SC&A’s opinion that individual 

monitoring for beta particles only works on 

a “yes/no” basis. The main concern is that a 

person may experience direct deposition of a 

hot particle on the skin or localized undetected 

beta exposure, and it is not detected, and the 

worker develops skin cancer later in his life. 

10/2/2007: SC&A’s main concern is the 

potential for direct deposition of a hot particle 

on the worker’s skin that is not detected, or 

localized undetected beta exposure.

10/14/2008: To improve the dose-to-the-skin 

reconstruction, the following should be 

considered:

– When the cancer site is on the hands, lower 

arm or face? Use workplace monitoring data.

– When the cancer site is on the thorax? Use 

individual monitoring data. 

– When the cancer site is on the lower legs or 

feet? Use both.

9/25/2007: OCAS and ORAUT disagree with 

this position. Consideration of geometry issues is 

discussed in the OTIB in the “Exposure 

Geometry” section, and it is discussed in the DR 

reports on a case-by-case basis. It is incumbent 

on the DR staff to analyze and discuss the 

potential for overestimating or underestimating 

electron dose with respect to the cancer location. 

In addition, ORAUT-OTIB-0017 recommends a 

claimant-favorable dose conversion factor of 1.0 

for application of measured electron dose to the 

skin.

11/7/2007: NIOSH explained that whether such 

exposures might have occurred is determined 

based on frisking data (for hot particles) and 

knowledge of the working conditions at the 

facility.

10/14/2008: SC&A recommended that 

Finding 3 be closed, not because everything 

is resolved, but because OTIB-0017 cannot 

be improved much further. The SCPR agreed 

with SC&A’s recommendation and closed 

Finding 3.

It should be noted that as a result of findings 

associated with an SC&A DR review, the 

skin exposure concern became an 

overarching issue and was addressed in 

NIOSH-OVER-0009.

4 It is possible to state definitely where the 

cancer site is, but not where the 

contamination was.

9/25/2007: Other data can be available to DR 

staff, such as claimant interview information and 

contamination incident reports. In addition, some 

work tasks involved partial body irradiation to

specific locations of the body that will be 

apparent to DR staff familiar with the site 

operations through the use of the site profile and 

other supporting documentation. In situations 

where the location of the partial-body exposure 

is not known, guidance in the section titled 

“Non-Uniform Exposure of the Skin of OTIB0017” regarding the development of a lognormal 

distribution of dose due to potential skin 

contamination can be used.

10/2/2007: Because Finding 4 also relates to 

the resolution of Finding 3, the SCPR 

transferred this finding to Finding 3 and 

closed it according to the resolution of 

Finding 3.
Issues Resolution Matrix for OTIB-0017 3 SC&A – March 23, 2018

NOTICE: This document has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 

Number Finding Description NIOSH Response Finding Resolution

5 A skin dose due to hot particle exposure will 

not be detected because of the localized 

nature of the exposure.

9/25/2007: Non-uniform dose can be considered 

by the DR using the guidance in the OTIB along 

with tools such as VARSKIN and guidance from 

site profile documents regarding the potential for 

hot particle exposure. As shown in the literature 

(see the Merwin and Moeller reference in the 

OTIB), hot particle dose can be extremely 

variable, thus making it difficult to establish a 

reference hot particle skin dose. If this were

possible, codes such as VARSKIN would not 

exist.

10/2/2007: Because Finding 5 also relates to 

the resolution of Finding 3, the SCPR 

transferred this finding to Finding 3and 

closed it according to the resolution of 

Finding 3.

6 SC&A questions why an adjustment is 

needed to an LOD value. If the dosimeter 

result was reported as an LOD value, then this 

value should be used as the basis for the 

missed dose calculation. 

10/2/2007: There were lengthy discussions 

about the calibration of dosimeters for low- vs.

high-energy photons and what values should 

be assigned to a worker who was exposed to 

low-energy photons but the dosimeter was 

calibrated for high-energy photons. 

12/11/2007: SC&A prepared a white paper on 

this issue that concluded the following: “If it is 

known that the film badge dosimeter 

overstated the dose from low-energy photons, 

and if it can be further ascertained that the 

LOD was expressed in terms of this overstated 

dose rather than the corrected dose, then we 

agree that it is appropriate to apply a 

correction factor to the LOD in assigning a 

missed dose from low-energy photons.”

9/25/2007: An adjustment to LOD is needed for 

the technical reasons stated in this section 

(over-response of film to low-energy photons), 

as specified below:

Although early film dosimeters were 

relatively accurate for measuring beta doses, 

they are known to have over-responded 

significantly to low-energy photons (such as 

those emitted from plutonium isotopes and 

daughter products). Although attempts were 

made at some sites to correct for the overresponse through calibration techniques or 

after-the-fact corrections, it is not always 

straightforward to reproduce the procedures 

adopted at the sites.

12/11/2007: Based on SC&A’s white paper 

on OTIB-0017, NIOSH and SC&A

concluded that they were in agreement. The 

SCPR concurred with this resolution and 

closed Finding 6.
Issues Resolution Matrix for OTIB-0017 4 SC&A – March 23, 2018

NOTICE: This document has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 

Number Finding Description NIOSH Response Finding Resolution

7 In Attachment A, “Non-Penetrating Doses 

to Organs Other Than the Skin,” it is not 

claimant favorable to consider that the 

employee had 4 mm of clothing thickness 

over the penis.

9/25/2007: Since the organ discussed in this 

section is the penis, the 4-mm assumption was 

made for pants and an undergarment – not a lab 

coat (although that could have been added), 

sweater, or shirt. The 4 mm measurement was 

confirmed a second time for this response.

10/2/2007: SC&A and the SCPR found this 

explanation acceptable, and the SCPR closed

Finding 7.

8 Attachment A provides a correction factor 

for the breast, penis, and testicle using a 

source that was modeled as a 10-cm2

infinitely thin disc source located 2 cm away 

from the skin. For the breast area, the film 

dosimeter would give a reasonable dose 

estimate. However, if the source was near 

the testicles, the film dosimeter would not 

measure anything.

9/25/2007: The comment is not relevant to the 

discussion in this section, which is related to 

modeling that was performed to determine 

appropriate correction factors for a range of beta 

energies. A discussion of dosimeter exposure 

geometry is provided on page 7 of the OTIB.

10/2/2007: There was extensive discussion about

other documents that address this issue and 

whether this document should cross-reference 

those documents. It was agreed that such a crossreferencing would be burdensome, given the 

evolving nature of the guidance documents. 

NIOSH explained that it currently relies on QA 

and training to ensure that the full array of 

guidance documents are being correctly 

employed in individual dose reconstructions. 

NIOSH also pointed out that the workbooks are 

designed to integrate the guidance contained in 

multiple documents, which also helps to prevent

this problem from arising.

10/2/2007: The SCPR concluded that the 

guidance in the OTIB with respect to this 

issue is adequate and closed Finding 8.

9 Tables A-1 and A-2 list correction factors 

for non-penetrating doses based on 

radionuclide. However, in nearly all cases, it 

is not possible to state the radionuclides that 

are responsible for the beta dose.

9/25/2007: The table provides benchmark 

correction factors for a range of beta energies. 

Site profile documents will typically provide 

information that will help the DR determine the 

proper energy range to use. In addition, the 

OTIB itself provides guidance with respect to 

uranium daughter products.

11/7/2007: SC&A and the SCPR agreed with 

NIOSH’s response, and the SCPR closed 

Finding 9.
Issues Resolution Matrix for OTIB-0017 5 SC&A – March 23, 2018

NOTICE: This document has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 

Number Finding Description NIOSH Response Finding Resolution

10 OTIB-0017 states that correction factors for 

lip dose are most notable for low-energy 

beta sources with maximum energies <500 

keV. However, for low-energy beta 

radiation, the dosimeters were likely 

incapable of furnishing accurate doses.

9/25/2007: DR staff would have to consider this 

on a case-by-case basis. The purpose of the 

OTIB is to provide general information for the 

DR staff to use along with other sources of 

information. If necessary, the hierarchy of data 

sources listed in IG-001 (Table 1.1) and PROC0006 (Table 5.2) includes the use of source term 

modeling.

11/7/2007: SC&A and the SCPR agreed with 

NIOSH’s response, and the SCPR closed 

Finding 10.

11 It is not clear why the two tables providing 

examples of skin dose assignments on pages 

21 and 24 give the recommendation to 

assign 30–250 keV for missed dose to the 

skin for 0 “OW reading” and 0 “S reading.”

9/25/2007: This radiation type and energy range 

was chosen because it is, in fact, claimant 

favorable compared to assigning the dose as 

electron dose (see IREP Technical Document).

11/7/2007: SC&A and the SCPR agreed with 

NIOSH’s response, and the SCPR closed 

Finding 11.

12 The logical order of the information in

Chapter 3, “General Approach,” could be 

improved.

9/25/2007: NIOSH agrees with SC&A’s finding. 

OTIB documents are revised for clarity as 

project time and resources allows. NIOSH will 

revise OTIB-0017 accordingly in the future.

11/7/2007: The SCPR agreed, and the 

finding was placed In Abeyance until 

NIOSH has the opportunity to revise the 

OTIB.

13 The OTIB does not identify any cases where 

a possibly high POC can be determined 

early in the investigation.

9/25/2007: PROC-0006, not OTIB-0017, is the 

document that would be used by DR staff to 

quickly triage a claim to determine the potential 

for high POC. It is important to consider the use 

of OTIB-0017 in the overall context of the DR 

process. In addition, OTIB-0017 does give 

guidance on the topic of low/high POC potential 

on page 6, items a, b, and c.

11/7/2007: SC&A and the SCPR agreed with 

NIOSH’s response. No further action is 

required, and the SCPR closed Finding 13.
Issues Resolution Matrix for OTIB-0017 6 SC&A – March 23, 2018

NOTICE: This document has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 

Number Finding Description NIOSH Response Finding Resolution

14 The OTIB is not claimant favorable in 

instances of unknown parameters affecting 

dose estimates. (Typically, the dosimeter 

location has no relationship to skin dose at the 

point of cancer incidence.)

9/25/2007: OCAS and ORAUT disagree with 

this position. Consideration of geometry issues is 

discussed in the OTIB and is addressed on a 

case-by-case basis. In addition, the OTIB makes

a recommendation (i.e., DCF = 1) to 

accommodate potential inaccuracies due to 

exposure geometry. The OTIB is claimant 

favorable in its recommendations regarding 

DCF, LOD, attenuation, and radiation 

type/energy range.

11/7/2007: SC&A and the SCPR agreed with 

NIOSH’s response. No further action is 

required, and the SCPR closed Finding 14.
Issues Resolution Matrix for OTIB-0017 7 SC&A – March 23, 2018

NOTICE: This document has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding

Number Finding Description NIOSH Response Finding Resolution

15 The OTIB does not employ scientifically 

valid protocols for reconstruction of doses:

(a)Page 6, item 3, of the OTIB states,

“Assign the non-penetrating dose as 

electrons >15 keV...or photons < 30 keV if 

the employee worked in a plutonium 

facility.” Either the dose was originally 

calculated as being due to electrons for 

betas or the equivalent calculation was 

made for photons.

(b)The assumption of 4 mm thickness of 

clothing for beta radiation shielding is 

not claimant favorable.

(c) The treatment of hot spots is not 

adequate.

9/25/2007: OCAS and ORAUT disagree with 

this position. 

Regarding item (a):

The guidance is given in order to assign the nonpenetrating dose as electrons or low-energy 

photons as necessary to complete a valid dose 

reconstruction using IREP. Dose is often given 

as “OW” and “S” or “shallow” and “deep” – not 

beta and gamma (although that condition does 

occur and DR staff will use that information in 

their analysis). 

Regarding item (b):

Since the organ discussed in this section of the 

OTIB is the penis, the 4-mm assumption was 

made for pants and an undergarment – not a lab 

coat (although that could have been added), 

sweater, or shirt as recommended in the general 

comments section of the SC&A review. The 

4-mm measurement for pants and an 

undergarment was confirmed a second time for 

this response. The selection of this clothing for 

this organ is appropriate.

Regarding item (c):

Non-uniform dose can be considered by the DR 

using the guidance in the OTIB along with tools 

such as VARSKIN and guidance from site 

profile documents regarding the potential for hot 

particle exposure. Additional information can be 

gained by analyzing claimant records and 

interviews.

11/7/2007: SC&A and the SCPR agreed with 

NIOSH’s response. No further action is 

required, and the SCPR closed Finding 15.

It should be noted that as a result of findings 

associated with an SC&A DR review, the 

non-uniform dose concern became an 

overarching issue and was addressed in 

NIOSH-OVER-0009.